1-2007 2078-A

ADEQ
MINOR SOURCE
AIR PERMIT

Permit No. : 2078-A

IS ISSUED TO:

Sherwood Marble Co., Inc.
15701 Highway 107
Jacksonville, AR 72076
Pulaski County
AFIN: 60-02392

THIS PERMIT IS THE ABOVE REFERENCED PERMITTEES AUTHORITY TO
CONSTRUCT, MODIFY, OPERATE, AND/OR MAINTAIN THE EQUIPMENT AND/OR
FACILITY IN THE MANNER AS SET FORTH IN THE DEPARTMENTS MINOR SOURCE
AIR PERMIT AND THE APPLICATION. THIS PERMIT IS ISSUED PURSUANT TO THE
PROVISIONS OF THE ARKANSAS WATER AND AIR POLLUTION CONTROL ACT
(ARK. CODE ANN. SEC. 8-4-101 ET SEQ.) AND THE REGULATIONS PROMULGATED
THEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED
HEREIN.

Signed:

Michael Bonds Date
Chief, Air Division
Permit #: 2078-A
AFIN: 60-02392

2
Table of Contents

Section I: FACILITY INFORMATION.................................................................................... 4
Section II: INTRODUCTION........................................................................................................ 5
Summary of Permit Activity.................................................................................................... 5
Process Description................................................................................................................... 5
Regulations ................................................................................................................................ 6
Total Allowable Emissions ....................................................................................................... 6
Section III: PERMIT HISTORY................................................................................................ 7
This is the initial Minor Source Air Permit for this existing facility. The facility previously
operated such that air emissions were below the thresholds which would require a permit. ......... 7
Section IV: EMISSION UNIT INFORMATION ..................................................................... 8
SN-01 Conditions ...................................................................................................................... 9
SN-02 Conditions ...................................................................................................................... 9
Section V: INSIGNIFICANT ACTIVITIES ........................................................................... 11
Section VI: GENERAL CONDITIONS................................................................................... 12

Permit #: 2078-A
AFIN: 60-02392

3
List of Acronyms and Abbreviations

A.C.A. Arkansas Code Annotated
AFIN ADEQ Facility Identification Number
CFR Code of Federal Regulations
CO Carbon Monoxide
HAP Hazardous Air Pollutant
lb/hr Pound Per Hour
No. Number
NO
x
Nitrogen Oxide
PM Particulate Matter
PM
10
Particulate Matter Smaller Than Ten Microns
SO
2
Sulfur Dioxide
Tpy Tons Per Year
UTM Universal Transverse Mercator
VOC Volatile Organic Compound
Permit #: 2078-A
AFIN: 60-02392

4
Section I: FACILITY INFORMATION

PERMITTEE: Sherwood Marble Co., Inc.

AFIN: 60-02392

PERMIT NUMBER: 2078-A

FACILITY ADDRESS: 15701 Highway 107
Jacksonville, AR 72076

MAILING ADDRESS: 6170 Getty Dr.
Sherwood, Arkansas 72117

COUNTY: Pulaski

CONTACT POSITION: Christy Organ

TELEPHONE NUMBER: (501) 835-7992

REVIEWING ENGINEER: David Triplett

UTM North South (Y): Zone 15: 3857.0

UTM East West (X): Zone 15: 573.6
Permit #: 2078-A
AFIN: 60-02392

5
Section II: INTRODUCTION

Summary of Permit Activity

Sherwood Marble Co. operates a cultured marble production facility located at 15701 Highway
107 in Jacksonville, Pulaski County, Arkansas. This will be the initial air permit for this existing
facility. This permit is necessary due to an anticipated increase in materials usage at the facility.

Permitted emission limits for the facility have been established at: 6.1 tons per year (tpy)
volatile organic compounds, 4.30 tpy styrene, 0.10 tpy methyl methacrylate, 0.1 tpy methyl ethyl
ketone, 1.50 tpy dimethyl phthalate, and 7.50 tpy Acetone.

Process Description

Sherwood Marble Co. custom manufactures synthetic marble sinks, vanities, bathtubs, and
showers. The synthetic marble fixtures are manufactured according to the following process.

First the product mold is moved into the gel coat spray booth (SN-01). There a gel coat is
applied to the product and allowed to dry. The spray booth is equipped with fibrous filters to
control overspray.

Then, a resin is mixed with marble dust and a catalyst in the resin application area (SN-02). This
resin mixture is poured into the plastic mold. The resin is then cured until it is solid. Emissions
from the resin application area are exhausted through five building general ventilation vents.

The cured product is removed from the mold and cleaned using acetone in the cleaning area (SN-
03).

The product is then moved to the grinding/buffing/finishing area (SN-04). In this area the
product is ground to trim the rough edges. The product is then buffed until the desired finish is
achieved. At this time any holes are drilled for necessary fixtures to be installed later. All
grinding and drilling is conducted in a Mar Max spray booth equipped with Glasfloss PR-5
filters. SN-04 has been designated as an insignificant activity.

The finished product is then warehoused to await final delivery to the customer.

Permit #: 2078-A
AFIN: 60-02392

6
Regulations

The following table contains the regulations applicable to this permit.

Regulations
Arkansas Air Pollution Control Code, Regulation 18, effective February 15, 1999
Regulations of the Arkansas Plan of Implementation for Air Pollution Control,
Regulation 19, effective December 19, 2004

The following table is a summary of emissions from the facility. This table, in itself, is not an
enforceable condition of the permit.

Total Allowable Emissions

TOTAL ALLOWABLE EMISSIONS
Emission Rates
Pollutant
lb/hr Tpy
VOC 20.7 6.1
Styrene 16.51 4.30
Methyl
Methacrylate
0.62 0.10
MEK 0.30 0.10
Dimethyl Phthalate 3.40 1.50
Acetone 10.00 7.50
Permit #: 2078-A
AFIN: 60-02392

7
Section III: PERMIT HISTORY

This is the initial Minor Source Air Permit for this existing facility. The facility previously
operated such that air emissions were below the thresholds which would require a permit.
Permit #: 2078-A
AFIN: 60-02392

8
Section IV: EMISSION UNIT INFORMATION

Specific Conditions

1. The permittee shall not exceed the emission rates set forth in the following table.
[Regulation 19, 19.501 et seq., effective December 19, 2004 and A.C.A. 8-4-203 as
referenced by A.C.A. 8-4-304 and 8-4-311]

SN Description Pollutant lb/hr tpy
01 Gel Coat Spray Booth VOC 10.5 1.5
02
Resin Application
Area
VOC 10.2 4.6

2. The permittee shall not exceed the emission rates set forth in the following table.
[Regulation 18, 18.801, effective February 15, 1999, and A.C.A. 8-4-203 as

SN Description Pollutant lb/hr tpy
01 Gel Coat Spray Booth
Styrene
Methyl Methacrylate
9.98
0.62
1.40
0.10
02
Resin Application
Area
Styrene
MEK
1

Dimethyl Phthalate
6.53
0.30
3.40
2.90
0.10
1.50
03 Cleaning Area Acetone 10.00 7.50
1 Methyl Ethyl Ketone

3. Visible emissions may not exceed the limits specified in the following table of this permit
as measured by EPA Reference Method 9. [A.C.A. 8-4-203 as referenced by A.C.A.
8-4-304 and 8-4-311]

SN Limit Regulatory Citation
01 5% 18.501
02 5% 18.501
03 5% 18.501

4. The permittee shall not cause or permit the emission of air contaminants, including odors
or water vapor and including an air contaminant whose emission is not otherwise
prohibited by Regulation #18, if the emission of the air contaminant constitutes air
pollution within the meaning of A.C.A. 8-4-303. [Regulation 18, 18.801 and
A.C.A. 8-4-203 as referenced by A.C.A. 8-4-304 and 8-4-311]
Permit #: 2078-A
AFIN: 60-02392

9

5. The permittee shall not conduct operations in such a manner as to unnecessarily cause air
contaminants and other pollutants to become airborne. [Regulation 18, 18.901 and

SN-01 Conditions

6. The permittee shall not process more than 12,000 pounds of gel coat material at SN-01
during any consecutive 12-month period. [Regulation 19, 19.705 and A.C.A. 8-4-203
as referenced by A.C.A. 8-4-304 and 8-4-311]
7. The permittee shall maintain monthly records which demonstrate compliance with
Specific Condition #6. The permittee will update the records by the fifteenth day of the
month following the month to which the records pertain. The permittee will keep the
records onsite, and make the records available to Department personnel upon request.
[Regulation 19, 19.705 and A.C.A. 8-4-203 as referenced by A.C.A. 8-4-304 and
8-4-311]
8. The permittee shall not use any gel coat material at SN-02 which contains hazardous air
pollutants (HAPs) in excess of the amounts shown in the following table. [18.1004 of
Regulation 18 and A.C.A. 8-4-203 as referenced by A.C.A. 8-4-304 and 8-4-311]

HAP Maximum Content
(wt %)
Styrene 42
Methyl Methacrylate 02

9. The permittee shall maintain MSDS or other records which demonstrate the maximum
HAP content of the gel coat materials in use at SN-01. These records shall be maintained
on-site and shall be made available to Department personnel upon request. [18.1004 of

SN-02 Conditions

10. The permittee shall not process more than 200,000 pounds of resin at SN-02 during any
consecutive 12-month period. [Regulation 19, 19.705 and A.C.A. 8-4-203 as
Permit #: 2078-A
AFIN: 60-02392

10
8-4-311]
12. The permittee shall not use any resin at SN-02 which contains styrene in excess of 23%
by weight. [18.1004 of Regulation 18 and A.C.A. 8-4-203 as referenced by A.C.A.
8-4-304 and 8-4-311]
13. The permittee shall not use any catalyst material at SN-02 which contains hazardous air
pollutants (HAPs) in excess of the amounts shown in the following table. [18.1004 of

HAP Maximum Content
(wt %)
MEK 5
Dimethyl Phthalate 60

14. The permittee shall maintain MSDS or other records which demonstrate the maximum
HAP content of the gel coat materials in use at SN-02. These records shall be maintained
on-site and shall be made available to Department personnel upon request. [18.1004 of

SN-03 Conditions
15. The permittee shall not process more than 15,000 pounds of acetone at SN-03 during any
consecutive 12-month period. [Regulation 19, 19.705 and A.C.A. 8-4-203 as
8-4-311]
Permit #: 2078-A
AFIN: 60-02392

11
Section V: INSIGNIFICANT ACTIVITIES

The Department deems the following types of activities or emissions as insignificant on the basis
of size, emission rate, production rate, or activity in accordance with Group A of the
Insignificant Activities list found in Regulation 18 and 19 Appendix A. Insignificant activity
emission determinations rely upon the information submitted by the permittee in an application
dated September 27, 2004.

Description Category
Grinding/Buffing/Finishing Area (SN-04) A-13
Permit #: 2078-A
AFIN: 60-02392

12
Section VI: GENERAL CONDITIONS

1. Any terms or conditions included in this permit that specify and reference Arkansas
Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air
Pollution Control Act (A.C.A. 8-4-101 et seq.) as the sole origin of and authority for the
terms or conditions are not required under the Clean Air Act or any of its applicable
requirements, and are not federally enforceable under the Clean Air Act. Arkansas
Pollution Control & Ecology Commission Regulation 18 was adopted pursuant to the
Arkansas Water and Air Pollution Control Act (A.C.A. 8-4-101 et seq.). Any terms or
conditions included in this permit that specify and reference Arkansas Pollution Control
& Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control
Act (A.C.A. 8-4-101 et seq.) as the origin of and authority for the terms or conditions
are enforceable under this Arkansas statute.

2. This permit does not relieve the owner or operator of the equipment and/or the facility
from compliance with all applicable provisions of the Arkansas Water and Air Pollution
Control Act and the regulations promulgated under the Act. [A.C.A. 8-4-203 as

3. The permittee will notify the Department in writing within thirty (30) days after
commencement of construction, completion of construction, first operation of equipment
and/or facility, and first attainment of the equipment and/or facility target production rate.
[Regulation 19, 19.704 and/or A.C.A. 8-4-203 as referenced by A.C.A. 8-4-304 and
8-4-311]

4. Construction or modification must commence within eighteen (18) months from the date
of permit issuance. [Regulation 19, 19.410(B) and/or Regulation 18, 18.309(B) and

5. The permittee must keep records for five years to enable the Department to determine
compliance with the terms of this permit such as hours of operation, throughput, upset
conditions, and continuous monitoring data. The Department may use the records, at the
discretion of the Department, to determine compliance with the conditions of the permit.
[Regulation 19, 19.705 and/or Regulation 18, 18.1004 and A.C.A. 8-4-203 as

6. A responsible official must certify any reports required by any condition contained in this
permit and submit any reports to the Department at the address below. [Regulation 19,
19.705 and/or Regulation 18, 18.1004 and A.C.A. 8-4-203 as referenced by A.C.A.
8-4-304 and 8-4-311]

Arkansas Department of Environmental Quality
Air Division
ATTN: Compliance Inspector Supervisor
Post Office Box 8913
Permit #: 2078-A
AFIN: 60-02392

13
Little Rock, AR 72219

7. The permittee will test any equipment scheduled for testing, unless stated in the Specific
Conditions of this permit or by any federally regulated requirements, within the following
time frames: (1) newly constructed or modified equipment within sixty (60) days of
achieving the maximum production rate, but no later than 180 days after initial start up of
the permitted source or (2) existing equipment already operating according to the time
frames set forth by the Department. The permittee must notify the Department of the
scheduled date of compliance testing at least fifteen (15) days in advance of such test.
The permittee must submit compliance test results to the Department within thirty (30)
days after the completion of testing. [Regulation 19, 19.702 and/or Regulation 18,
18.1002 and A.C.A. 8-4-203 as referenced by A.C.A. 8-4-304 and 8-4-311]

8. The permittee will provide: [Regulation 19 , 19.702 and/or Regulation 18 , 18.1002
and A.C.A. 8-4-203 as referenced by A.C.A. 8-4-304 and 8-4-311]

a. Sampling ports adequate for applicable test methods
b. Safe sampling platforms
c. Safe access to sampling platforms
d. Utilities for sampling and testing equipment

9. The permittee will operate equipment, control apparatus and emission monitoring
equipment within their design limitations. The permittee will maintain in good condition
at all times equipment, control apparatus and emission monitoring equipment.
[Regulation 19, 19.303 and/or Regulation 18, 18.1104 and A.C.A. 8-4-203 as

10. If the permittee exceeds an emission limit established by this permit, the permittee will be
deemed in violation of said permit and will be subject to enforcement action. The
Department may forego enforcement action for emissions exceeding any limits
established by this permit provided the following requirements are met: [Regulation 19,
19.601 and/or Regulation 18, 18.1101 and A.C.A. 8-4-203 as referenced by A.C.A.
8-4-304 and 8-4-311]

a. The permittee demonstrates to the satisfaction of the Department that the
emissions resulted from an equipment malfunction or upset and are not the result
of negligence or improper maintenance, and the permittee took all reasonable
measures to immediately minimize or eliminate the excess emissions.
b. The permittee reports the occurrence or upset or breakdown of equipment (by
telephone, facsimile, or overnight delivery) to the Department by the end of the
next business day after the occurrence or the discovery of the occurrence.
c. The permittee must submit to the Department, within five business days after the
occurrence or the discovery of the occurrence, a full, written report of such
occurrence, including a statement of all known causes and of the scheduling and
nature of the actions to be taken to minimize or eliminate future occurrences,
Permit #: 2078-A
AFIN: 60-02392

14
including, but not limited to, action to reduce the frequency of occurrence of such
conditions, to minimize the amount by which said limits are exceeded, and to
reduce the length of time for which said limits are exceeded. If the information is
included in the initial report, the information need not be submitted again.

11. The permittee shall allow representatives of the Department upon the presentation of
credentials: [A.C.A. 8-4-203 as referenced by A.C.A. 8-4-304 and 8-4-311]

a. To enter upon the permittee's premises, or other premises under the control of the
permittee, where an air pollutant source is located or in which any records are
required to be kept under the terms and conditions of this permit;
b. To have access to and copy any records required to be kept under the terms and
conditions of this permit, or the Act;
c. To inspect any monitoring equipment or monitoring method required in this
permit;
d. To sample any emission of pollutants; and
e. To perform an operation and maintenance inspection of the permitted source.

12. The Department issued this permit in reliance upon the statements and presentations
made in the permit application. The Department has no responsibility for the adequacy or
proper functioning of the equipment or control apparatus. [A.C.A. 8-4-203 as

13. The Department may revoke or modify this permit when, in the judgment of the
Department, such revocation or modification is necessary to comply with the applicable
provisions of the Arkansas Water and Air Pollution Control Act and the regulations
promulgated the Arkansas Water and Air Pollution Control Act. [Regulation 19,
19.410(A) and/or Regulation 18, 18.309(A) and A.C.A. 8-4-203 as referenced by
A.C.A. 8-4-304 and 8-4-311]

14. This permit may be transferred. An applicant for a transfer must submit a written request
for transfer of the permit on a form provided by the Department and submit the disclosure
statement required by Arkansas Code Annotated '8 1 106 at least thirty (30) days in
advance of the proposed transfer date. The permit will be automatically transferred to the
new permittee unless the Department denies the request to transfer within thirty (30) days
of the receipt of the disclosure statement. The Department may deny a transfer on the
basis of the information revealed in the disclosure statement or other investigation or,
deliberate falsification or omission of relevant information. [Regulation 19, 19.407(B)
and/or Regulation 18, 18.307(B) and A.C.A. 8-4-203 as referenced by A.C.A. 8-4-
304 and 8-4-311]

15. This permit shall be available for inspection on the premises where the control apparatus
is located. [A.C.A. 8-4-203 as referenced by A.C.A. 8-4-304 and 8-4-311]

Permit #: 2078-A
AFIN: 60-02392

15
16. This permit authorizes only those pollutant emitting activities addressed herein. [A.C.A.
8-4-203 as referenced by A.C.A. 8-4-304 and 8-4-311]

17. This permit supersedes and voids all previously issued air permits for this facility.
[Regulation 18 and 19 and A.C.A. 8-4-203 as referenced by A.C.A. 8-4-304 and 8-4-
311]

18. The permittee must pay all permit fees in accordance with the procedures established in
Regulation No. 9. [A.C.A 8-1-105(c)]

APPENDIX A

APPENDIX B

APPENDIX C

Request for PDS Invoice

Invoice Number
(assigned when invoice printed)

PDS-

AFIN

60-02392

Name
(for confirmation only)


Initial X

Mod

Variance

Invoice Type (pick one)

Annual

Renewal

Interim
Authority

Permit Number

2078-A

Media Code

A

Fee Code or Pmt Type

MS

Fee Description
(for confirmation only)
Minor Source

Amount Due
(whole dollar amount only)

$ 500

Printed Comment
(600 characters maximum)

Minimum minor source initial permit fee

Note: The information below is for use by the requesting division if desired; it will not print on the invoice.

Engineer

David Triplett

Paid? (yes/no)

Check number

Comments

Required data(See "g:\Misc\PDS_FeeCodes.wpd" for descriptions and discussions of fee codes)

Request submitted by:

Date:

Public Notice

Pursuant to A.C.A. 8-4-203, and the regulations promulgated thereunder, the Air Division of
the Arkansas Department of Environmental Quality gives the following notice:

Sherwood Marble Co. operates a cultured marble production facility located at 15701 Highway
107 in Jacksonville, Pulaski County, Arkansas. This will be the initial air permit for this existing
facility. This permit is necessary due to an anticipated increase in materials usage at the facility.
Permitted emission limits for the facility have been established at: 6.1 tons per year (tpy)
volatile organic compounds, 4.30 tpy styrene, 0.10 tpy methyl methacrylate, 0.1 tpy methyl ethyl
ketone, 1.50 tpy dimethyl phthalate, and 7.50 tpy Acetone.

The application has been reviewed by the staff of the Department and has received the
Department's tentative approval subject to the terms of this notice.

Citizens wishing to examine the permit application and staff findings and recommendations may
do so by contacting Doug Szenher, Public Affairs Supervisor. Citizens desiring technical
information concerning the application or permit should contact, David Triplett, Engineer. Both
Doug Szenher and David Triplett can be reached at the Department's central office, 8001
National Drive, Little Rock, Arkansas 72209, telephone: (501) 682-0744.

The draft permit and permit application are available for copying at the above address. A copy
of the draft permit has also been placed at the Little Rock Public Library located at 100 South
Rock St. in Little Rock, Pulaski County, Arkansas. This information may be reviewed during
normal business hours.

Interested or affected persons may also submit written comments or request a hearing on the
proposal, or the proposed modification, to the Department at the above address Attention: Doug
Szenher. In order to be considered, the comments must be submitted within thirty (30) days of
publication of this notice. Although the Department is not proposing to conduct a public
hearing, one will be scheduled if significant comments on the permit provisions are received. If
a hearing is scheduled, adequate public notice will be given in the newspaper of largest
circulation in the county in which the facility in question is, or will be, located.

The Director shall make a final decision to issue or deny this application or to impose special
conditions in accordance with Section 2.1 of the Arkansas Pollution Control and Ecology
Commissions Administrative Procedures (Regulation #8).

Dated this

Marcus C. Devine
Director

1-2007 2078-A

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